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Page 1 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Item No. Issue Issue explanation Revised/updated NIOSH response

Finding 1 Air Samples May 

Not Represent 

Concentrations 

Breathed by 

Workers

It appears that the white paper 

uses the terms BZ, room air, 

and work area air samples 

interchangeably. However, as

indicated in the quoted LBNL 

documents above, room air or 

work area air samples may not 

represent the radionuclide 

concentrations in the BZ of 

workers. This is a problem that 

has been recognized at other 

DOE sites and applies to LBNL 

also. The use of room air or 

work area air samples could 

lead to a sufficient 

underestimate of the worker’s

intakes when the worker is 

located close to the source and 

the air sampler is located

elsewhere.

October 2018 Update (submitted to the WG chair via email 10/24/18 and updated BRS 

entry)

The terms “room air samples” and “BZ air samples” were used interchangeably in the LBNL 

DR Methodology. NIOSH understands this interchanging of terms could lead to confusion 

and lack of clarity. While the air samples were referred to as “work area” and “room air” in 

the LBNL DR Methodology white paper and various LBNL air sampling references, NIOSH 

attests all air samples used in the LBNL DR Methodology are representative of the breathing 

zone and provides additional justification below. 

Per OCAS-IG-002: 

The general approach to using workplace monitoring data is to determine as closely 

as possible the airborne radioactivity concentration in the individual’s breathing zone. 

... The best data for determining airborne concentrations are from job specific air 

samples. Since the individual’s breathing zone is the location of interest, lapel type 

breathing zone air samples are preferred. (OCAS 2002, p. 20)

As quoted above from OCAS-IG-002, breathing zone samples are air samples of the 

potential airborne radioactivity concentration in the worker’s breathing zone. As a note, 

IG-002 doesn’t state or imply that the only BZ sampling is lapel sampling. 

According to NRC Regulatory Guide 8.25 and NUREG 1400, the criterion for a portable 

sampler to be representative of the breathing zone it is: 

Located within 1 foot of the worker’s head and the sampler is sensitive enough to 

obtain a lower limit of detection less than 4 DAC-hr for samples collected over 40-

hour period (NRC 1993 p. 1.8, NRC 1992). 
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 2 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

It continues saying that 

Breathing zone samplers should intercept radioactive material before it reaches or 

soon after it passes the individual worker. Therefore, if fixed-location air samplers are 

placed strategically in a work area, they too can be used to collect representative 

samples of the air that workers inhale (NRC 1993, p. 1.8). 

Strategic placement would be based on knowledge of the typical work area air 

concentrations and air flow studies (NRC 1993). 

The American National Standard Institute/Health Physics Society Standard (ANSI/HPS 

N13.56-2012) on “Sampling and Monitoring Releases of Airborne Radioactivity in the 

Workplace,” has a similar definition of breathing zone: 

A general description of the volume of air directly around the worker’s upper body 

and head, which may be drawn into the lungs during the course of breathing. An air 

sample representative of the breathing zone is usually considered to be 

representative if drawn from within about 30cm of the worker’s head (HPS 2012, p. 

2).

A breathing zone air sampler (BZA), according to ANSI/HPS N13.56-2012, “may also refer to 

a fixed air sampler at a work location, such as a glovebox where the sample head is located 

within about 30 cm of the worker’s head” (HPS 2012 p. 2).

There was LBNL guidance on the placement of air samplers as early as 1951. This guidance, 

cited in the LBNL DR Methodology, was to keep the air sampler close to the scene of 

radioactive operations, such as gloveboxes and hoods (LBL 1951). This results in samplers 
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 3 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

placed at the work location, which is presumed to be closer to the source than the worker 

(i.e., intercept the radioactive material before it reaches the worker). This sampler 

placement will likely lead to higher activities being sampled because there is less dilution 

than in the breathing zone which is further from the work than the sampler. Air samplers 

placed on the glovebox or at the hood face, directly meet the present day ANSI/HPS 

standard definition of a breathing zone sample (HPS 2012). Figure HP 891 of (LRL 1968) 

shows an LBNL BZ air sampler head placed on a glovebox. 

In addition, LBNL BZ air samples were sensitive enough to obtain a lower limit of detection 

of less than 4 DAC-hr for samples collected over a 40-hour period (NRC 1992 criterion), 

illustrated in the following description. The LBNL computer printouts of monthly BZ air 

sample results used in the LBNL DR Methodology reported minimum positive air 

concentrations of 0.001 pCi/m3 alpha and 0.01 pCi/m3 beta/gamma activity. The limiting 

MPCs used by LBNL were 0.2 pCi/m3 alpha and 100 pCi/m3 beta/gamma, and are referenced 

in Attachment B of the whitepaper. Dividing the minimum reported alpha and beta/gamma 

air concentrations by their limiting MPCs, multiplying by 40 hours, and multiplying by a 

factor of 4.2 (upper bound adjustment for weekly and daily sampling performed by LBNL) 

results in a sensitivity of approximately 0.9 MPC-hr alpha, and approximately 0.02 MPC-hr

beta/gamma activity. To be clear, the LBNL limiting MPC is the assumed “DAC” for this 

scenario and the calculated MPC-hr for the minimum positive air concentrations are all less 

than 4. It was also LBNL policy that when radioactive operations were moved to another 

place in the room, the air samplers (i.e., Filter Queens) were to be moved accordingly (LBL 

1951). Therefore, LBNL air sample placement policy is in line with BZ air sample definitions 

in current day standards (NRC 1992, 1993 and HPS ANSI 13.56-2012). 

In addition, early LBNL policy required use of gloveboxes for the handling of dispersible 

radioactive material. Work enclosures, including gloveboxes, constituted the basic 

component for handling large or small quantities of the various types of radioactive 
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 4 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

materials at LBNL (Garden 1960). Environmental Health and Safety Department procedures 

indicated that ventilated gloveboxes were to be used for all radioactive operations that 

could generate aerosols, or the possible spread of contamination (LBNL 1981). 

Given the LBNL guidance on placement of air samplers close to the scene of radioactive 

operations such as at gloveboxes and hoods, and the policy of using gloveboxes and 

enclosures for the handling of dispersible radioactive material, the air samples used in the 

LBNL DR Methodology are considered to be representative of (or higher than) the breathing 

zone of the worker. Clarification of terms used to describe the air sampling data will be 

updated in the white paper, including the additional explanation about why NIOSH attests 

the air samples are representative of the breathing zone.

An additional review was made by NIOSH. All air samples used in the LBNL DR Methodology

came from the monthly summary reports that listed BZ sampling locations with air 

concentration results greater than or equal to 1% of the MPC and computer printouts of BZ 

air sampling (i.e., Filter Queen) results. All of these samples were used to determine the 

95th-percentile annual average air concentrations reported in the LBNL DR Methodology. 

In addition, NIOSH reiterates specific reasons why the current approach ensures that the 

unmonitored intakes assigned from this analysis are favorable to the claimant, which

include:

1. Assessing the air concentration at the 95th percentile;

2. The monthly summary reports used only listed BZ locations whose air concentrations 

were greater than or equal to 1% of the MPC/DAC. All results that were less than 1% of 

the MPC/DAC (censored) were imputed with (assumed to be) 1% of the MPC/DAC. In 

addition, blank, zero, or negative results in the computer printout data were imputed 

with the minimum positive reported air concentrations of 0.001 pCi/m3 alpha and 0.01 
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 5 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

pCi/m3 beta/gamma. Approximately 97 percent of the LBNL BZ air sample data was 

imputed. In other words, most of the BZ air data was below the 1% MPC/DAC, or were 

either blank, zero or negative results. Given the amount of imputed data, the distribution 

parameters are driven by the imputed values, which leads to a higher 95th percentile air 

concentration than if the values were not imputed in this way and all actual values were 

used. This is seen in the 95th percentile annual average BZ beta/gamma air 

concentrations. Most of the results for the years listed were at the censoring level of 1% 

of the MPC/DAC which is 4.2 pCi/m3

; 

3. LBNL performed continuous 24-hour BZ air sampling, typically on a daily or weekly basis. 

Assuming all air samples were collected weekly, and adjusting all air concentrations up by 

a factor of 4.2 for a 40 hour work week biases the air concentrations high; 

4. Using the most favorable radionuclide resulted in the highest dose; 

5. Assuming the exposure was for the entire employment period, when most operational 

campaigns lasted on the order of weeks; 

6. Assuming the exposure occurred from the most favorable alpha and beta radionuclide at 

the same time, when it is unlikely that any individual worked with both concurrently.

April 5, 2019 WG Meeting

At the 4/5/19 LBNL WG meeting, NIOSH provided the following path forward for Finding 1:

NIOSH will revise the WP, as suggested in previous responses, as well as incorporating 

additional justification and information regarding the placement of air samplers to better 

justify the representativeness of the air sampling results used in this methodology.

October 2019 Update

NIOSH is in the process of completing interviews to support, as well as refine, a data capture 

request, in response to this finding. At this time NIOSH has completed 2 interviews (SRDB

Ref. ID 178601 and 178602).
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 6 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

Finding 2 Technical Issues 

and 

Uncertainties 

with Gross 

Counting Data 

Conversion to 

Concentration/

Intake for Use in 

Dose 

Reconstruction

Applying an air sample activity 

or bioassay sample activity, in 

units of recorded dpm or 

picocuries from gross counting, 

to different radionuclides for 

determining air concentrations 

or intakes, as proposed in the 

white paper, could lead to an 

underestimate of the intake 

because detector efficiency is 

dependent on the energy of the 

emitted radiation, and hence, 

the radionuclide, leading to 

large uncertainties.

The backscatter, sample selfabsorption, air and window 

absorption, and detector 

intrinsic efficiency will vary 

depending on the radionuclide 

present, even if all the physical 

counting parameters remain 

constant.

October 2018 Update (submitted to the WG chair via email 10/24/18 and updated BRS 

entry)

SC&A cited potential underestimates when converting from gross counting methods to 

activity since these counting methods were calibrated for a specific radionuclide. Typically, 

an Am-241 standard was used for alpha air sample and alpha bioassay counter efficiency 

calibration, and a Sr-90/Y-90 standard was used for beta/gamma air sample and beta 

bioassay counter efficiency calibration at LBNL. 

Both the BZ air sampling intake rates and those based on bioassay for individual 

radionuclides can be adjusted for efficiency changes with energy. NIOSH will first 

determine if information can be found regarding the specific detectors in use at LBNL and 

any site specific data for efficiency calibration by energy. This will require additional effort 

in compiling available detector system information and efficiency data, and possible 

additional data captures. If site-specific information cannot be found, general detector 

assumptions will be made and an efficiency calibration by energy factor will be calculated 

and applied to the measurements, if deemed significant.

April 5, 2019 WG Meeting

At the 4/5/19 LBNL WG meeting, NIOSH provided the following path forward for Finding 2:

NIOSH will research site-specific detector system and efficiency calibration information. If 

site-specific information is not available, NIOSH will assume typical equipment during the 

time period. NIOSH will determine if accounting for efficiency will make a significant 

difference in the assigned doses.

As our research is finalized and the approach is developed, NIOSH will provide additional 

responses to the WG.

October 2019 Update
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

NIOSH is in the process of completing interviews to support, as well as refine, a data capture 

request, in response to this finding. At this time NIOSH has completed 2 interviews (SRDB

Ref. ID 178601 and 178602).

Obs. 1 Potentially 

Missed 

Radionuclides

It has not been demonstrated 

that the radionuclides listed in 

the white paper are all-inclusive 

of the potential radionuclides 

intakes at LBNL that are needed 

for adequate dose 

reconstruction for 1962 

forward.

October 2018 Update (submitted to the WG chair via email 10/24/18 and updated BRS 

entry)

SC&A cited iodine radionuclides as not being included [i.e., iodine-123 (I-123), I-125, I-129, 

and I-131]. Iodine was measured separately using charcoal air samples and likely would not 

be detected by the Filter Queen air samples. Monovalent X-ray emitters were determined 

in the raw urine sample. This was a separate count performed after counting the raw urine 

sample for gamma emitters, and would be based on the bioassay list selection. The 

principle radionuclide of interest in this assay is I-125 (LBL 1989). I-123 (half-life = 13.27 

hours) and I-131 (half-life = 8 days) were listed as being measured by whole body counts in 

the LBNL Site Profile (ORAUT 2010). I-129 is an X-ray emitter and would likely be detected 

by either the X-ray emitters’ bioassay method, or whole body counts. As a result, the

radioiodines were not included in this LBNL DR Methodology, which utilized alpha, beta, and 

gamma gross bioassay methods, and alpha and beta/gamma air BZ sample results. 

SC&A scanned the LBNL site profile and found other radionuclides listed that are not 

included in the white paper [e.g., erbium-165 (Er-165), Er-169, fermium-237, rhodium-102, 

and scandium-93]. Erbium-165 (half-life = 10.36 hours) is below the short half-life cutoff 

provided in the LBNL DR Methodology. There are no radionuclides named Sc-93 and Fm237. These are likely typographical errors, and will be corrected during revision of the site 

profile.

Erbium-169 and Rh-102, along with any additional radionuclides identified from the Site 

Profile, will be added to the final LBNL DR Methodology implementation.

April 5, 2019 WG Meeting
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

At the 4/5/19 LBNL WG meeting, NIOSH reiterated the following path forward:

(1) NIOSH will update the white paper to include the 2 radionuclides not previously 

included (Er-169 and Rh-102).

(2) Correct typos in the Site Profile in the next revision (Sc-93 and Fm-237)

October 2019 Update

NIOSH is in the process of determining if Sc-93 and Fm-237 are typos. 

Sc-93 is listed in the LBNL Site Profile (ORAUT-TKBS-0049) and is found in numerous Site 

Environmental Reports (SRDB Ref. IDs 112486, 113034, 113274 and 141110 for example), so 

it is most likely that this typo was carried over from those reports to the Site Profile. During 

the 2 interviews performed in support of other issue responses, NIOSH has asked for 

additional references or contacts that worked on the environmental reports where these 

nuclides were listed. NIOSH will update the WG with any additional information as it 

becomes available.

Fm-237 is not listed in the LBNL Site Profile (ORAUT-TKBS-0049). NIOSH believes this was a 

typo in the SC&A WP Methodology Review (SCA-TR-2018-SP003). To thoroughly investigate 

this, NIOSH looked in the Site Environmental Reports listed above for Fm-237, and it was not 

listed. However, Fm-257 is listed in both the Site Profile and the Site Environmental Reports 

but was inadvertently left out of the WP Methodology. Fm-257 will be added to the final 

LBNL DR Methodology implementation. 

Obs. 2 Bioassays in 

Claimant DOE 

Files May Not 

Be Indicative of 

Exposure 

Given the observed limitations 

in ascribing internal monitoring 

data to an individual claimant, 

the presence of internal 

monitoring results in individual 

claim files may not be an 

October 2018 Update (submitted to the WG chair via email 10/24/18 and updated BRS 

entry)

SC&A reviewed bioassay records provided by DOE for a number of LBNL claimants and 

bioassay records obtained from site data capture in the SRDB (Site Research Database). 

(Note: The LBNL site radiation safety program typically reviews dosimetry records and sends 
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 9 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

Potential appropriate criterion for 

determining whether 

occupational intakes should be 

applied in lieu of ambient 

environmental intakes. An 

alternate approach of assigning 

occupational intakes, unless 

clear evidence exists of “little to 

no exposure potential,” would 

be more claimant favorable and 

consistent with dose 

reconstruction procedures for 

other sites.

them via the DOE regional office, based on the NIOSH records request. This is referred to as 

the DOE submission.) They cited missing bioassay data in the DOE records provided to 

NIOSH via two methods of review: (1) introductory letters attached to the DOE-provided 

dosimetry records indicating that a number of bioassay samples were taken for the EE, but 

no bioassay records were provided, or OCAS-INT-004 form indicating the EE was not 

monitored; and (2) records found in the SRDB documents indicating internal monitoring. If 

the letter/form or SRDB document indicated bioassay records and they weren’t included in 

the DOE response file, the claim was flagged for a discrepancy. If the OCAS-INT-004 form 

indicated no bioassay records existed and SRDB document indicated bioassay records, the 

claim was flagged for a discrepancy.

As a part of the dose reconstruction process, the EE’s DOL initial case file is reviewed (e.g., 

for monitoring data, X-rays, investigation reports). SRDB searches (e.g., for EE name, 

employee number) are also performed for additional information or data pertinent to the 

dose reconstruction. This process of linking this SRDB information for LBNL claims began 

consistently in 2013. Any data and or additional information is included in the total claim 

file and considered in the dose reconstruction, regardless of the information provided by

DOE. 

Background on LBNL claims records: In 2010, it was determined that occupational X-ray 

information was not being sent to NIOSH, because they were stored in the LBNL medical 

records. Medical records are provided by a site as part of the DAR (Department of Labor’s 

request for all worker’s records). These worker records include medical, industrial hygiene, 

human resources, dosimetry, etc. However, LBNL medical records were not being received

prior to this time. At that time, NIOSH began receiving the EE’s LBNL medical file in the DOL 

initial case file, which provided NIOSH with the X-ray information. Around 2011, NIOSH 

pursued re-requesting all pre-2010 claims for reviewing and re-sending of DOE records

including the medical file, but given the workload by the LBNL site staff this was denied. 

NIOSH did not further pursue the LBNL record re-request, since the LBNL Site Profile would 
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 10 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

be revised for the LBNL DR Methodology, and a PER issued. A records re-request would be 

part of the PER process.

Recently, it was determined that the LBNL dosimetry records provided in the DOE response 

file may not have included all the bioassay records for an EE, based on a review of the 

medical records in the DOL file. This is because a copy of the bioassay records are also 

saved in the EE’s LBNL medical file, according to bioassay laboratory record keeping 

procedures (LBL 1989). All LBNL claims received since 2010 have contained the bioassay 

records in the EE’s LBNL medical file located in the DOL initial case file. 

It should be noted that SC&A cited all but one claim that was received prior to this 2010 

timeframe that did not have the EE’s LBNL medical records in the DOL Initial case file. One 

claim SC&A cited was received after 2010, and contained the bioassay record in the medical 

file.

Therefore, in response to this observation and observation #3, NIOSH determined the 

current status of records receival from DOE, by reviewing all NOCTS claims post-2010 for 

discrepancies between the DOL initial case file and the DOE response file. Only 2 of the 105 

claims NIOSH reviewed had discrepancies, where the DOL initial case file had additional 

bioassay results that the DOE response file did not provide. 

For these two claims, NIOSH has re-requested the data review and response from DOE and 

pointed out the discrepancies. NIOSH will request that LBNL/DOE begin sending the entire 

medical file as part of their response, since the x-ray information and bioassay results are 

included in this file. As for pre-2010 claims, NIOSH has begun the process of requesting that 

DOE/LBNL re-review and re-send records for all non-compensatory, non-SEC claims, using 

the new process of sending the entire medical file. 

With this records request process, including the entire LBNL medical file, in conjunction with 
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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

the typical DR SRDB review, DOL initial case file review, and CATI review, NIOSH is confident 

in its ability to ascribe exposure potential for the LBNL employees given the LBNL policy of 

monitoring workers who worked with or in areas that contained unsealed radioactive 

sources. If from this review it is determined the worker has a potential for radiation 

exposure, then dose will be assigned according to the methodology in this white paper. 

As pointed out by SC&A, clarification is needed in the white paper for the ‘partially’ 

monitored worker where an alternate approach of assigning occupational intakes in lieu of 

environmental intakes would be more claimant favorable, unless clear evidence exists of 

little to no exposure potential. NIOSH will provide further clarification in the whitepaper on 

assigning occupational intakes based on the air sampling approach versus environmental 

intakes for an unmonitored worker. 

April 5, 2019 WG Meeting

At the 4/5/19 LBNL WG meeting, NIOSH provided the following update for Observation 2:

NIOSH made a mass re-request of data from LBNL for all claims that were submitted to 

NIOSH prior to 2010 and were not compensated under the SEC or through the dose 

reconstruction process (DR POC<50%). This equaled 166 claims. Of these 166 claims NIOSH 

has received responses with updated data files for 25 of them. An additional 52 of the 

claims didn't have a medical file and NOCTS was updated with this information. NIOSH is 

working with LBNL to determine the best way to transmit the data for the remaining 89.

With this medical file and the dosimetry data provided by LBNL, as well as the CATI 

information available for a claim, NIOSH is able to determine the exposure potential for 

LBNL employees.

NIOSH has agreed to clarify within the white paper the determination of the unmonitored 
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 12 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

worker including: 

(1) partially monitored worker scenario that was discussed

(2) determining an unmonitored worker with potential for radiation exposure (e.g., 

radiation worker) vs. unmonitored worker without potential for exposure (e.g., 

administrative staff).

Per the transcript (attached, p. 86-87), SC&A suggested and the WG agreed with reviewing 

the data provided in the mass re-request to determine if this cleared up the issues of 

missing data that were previously found.

October 2019 Update

As discussed in previous matrix/BRS entries, on December 4, 2018, NIOSH made a mass rerequest of “the complete medical records file” for LBNL claims that had been received prior 

to 2010. By September 12, 2019, NIOSH received responses to all requests, had screened 

responses for new information, and reviewed the new information to determine priority for 

dose reconstruction revisions, as well as determined if the new information changed the 

determination of exposure potential for the EEs. 

This LBNL mass supplemental request was made for 168 claims (updated number). Of these

168 claims, 53 claims had no record of a medical file and needed no further review. 

Additionally, there was 1 claim that had been submitted with a probability of causation 

(PoC) over 50%, which needed no further screening.

For the remaining 114 claims, 109 claims had no new bioassay information, 3 claims had 

new bioassay information compared to what LBNL had previously provided but this 

information was available to NIOSH from other documents (DOL files, data captures, etc.), 

and 2 claims had totally new bioassay information. Therefore, only 2 of the 168 (~1.2%) 
Effective Date: 10/29/2019 (Final) Responses to SCA-TR-2018-SP003 Page 13 of 18

Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 13 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

claims had totally new information that was not previously available to NIOSH. 

These 5 claims that had new bioassay information received from LBNL were reviewed for 

impact. The PoC remained under 50% for these claims when the new information was 

assessed. 

Given this observation is specific to whether exposure potential could be determined based 

on the records provided by DOE. The exposure potential decision and thus application of 

the WP methodology was reviewed for the information previously available to NIOSH (when 

the DR was completed) and reviewed with the information provided in this mass records 

request. As stated above there were 5 claims with new bioassay information. Given the 

original basis of implementation for this new WP methodology on the existence of bioassay 

data, 2 (of the 5) claims would not have had the methodology applied with claim 

information available at the time of the last DR (i.e., no bioassay results were present before 

this request), 2 could have been affected (i.e., bioassay results present before request, 

additional results provided, which could have led to longer application of the bioassay 

approach of the methodology; determination of whether to apply the unmonitored 

approach for the rest of employment would be up to the dose reconstructor based on other 

claim information), and 1 claim would not have been affected at all (i.e., no additional 

samples provided, only additional detail for the already provided sample). Therefore, only 4 

of all 168 claims (~2.4%) would have potentially been affected by the exposure potential 

determination based on bioassay sample existence.

As proposed in previous matrix/BRS responses, NIOSH will clarify that the exposure 

potential decision, and therefore application of the doses calculated from this methodology, 

is based not only on the presence of internal bioassay monitoring for an EE, but also job 

title, CATI, and any other claim information. This discussion is especially important for the 

application of the unmonitored worker approach, which uses the air sampling data. 
Effective Date: 10/29/2019 (Final) Responses to SCA-TR-2018-SP003 Page 14 of 18

Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 14 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

Obs. 3 Bioassays in 

Claimant DOE 

Files May Not 

Be Complete 

Compared to 

LBNL 

Documents

SC&A’s sample analysis of 36 

LBNL claims found that 13 of the 

DOE files for the 36 claims did 

not contain all the bioassay 

records indicated in the SRDB

documents.

October 2018 Update (submitted to the WG chair via email 10/24/18 and updated BRS 

entry)

SC&A reviewed bioassay records provided by DOE for a number of LBNL claimants and 

bioassay records obtained from site data capture in the SRDB (Site Research Database). 

(Note: The LBNL site radiation safety program typically reviews dosimetry records and sends 

them via the DOE regional office, based on the NIOSH records request. This is referred to as 

the DOE submission.) They cited missing bioassay data in the DOE records provided to 

NIOSH via two methods of review: (1) introductory letters attached to the DOE-provided 

dosimetry records indicating that a number of bioassay samples were taken for the EE, but 

no bioassay records were provided, or OCAS-INT-004 form indicating the EE was not 

monitored; and (2) records found in the SRDB documents indicating internal monitoring. If 

the letter/form or SRDB document indicated bioassay records and they weren’t included in 

the DOE response file, the claim was flagged for a discrepancy. If the OCAS-INT-004 form 

indicated no bioassay records existed and SRDB document indicated bioassay records, the 

claim was flagged for a discrepancy.

As a part of the dose reconstruction process, the EE’s DOL initial case file is reviewed (e.g., 

for monitoring data, X-rays, investigation reports). SRDB searches (e.g., for EE name, 

employee number) are also performed for additional information or data pertinent to the 

dose reconstruction. This process of linking this SRDB information for LBNL claims began 

consistently in 2013. Any data and or additional information is included in the total claim 

file and considered in the dose reconstruction, regardless of the information provided by 

DOE.

Background on LBNL claims records: In 2010, it was determined that occupational X-ray 

information was not being sent to NIOSH, because they were stored in the LBNL medical 

records. Medical records are provided by a site as part of the DAR (Department of Labor’s 

request for all worker’s records). These worker records include medical, industrial hygiene,
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 15 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

human resources, dosimetry, etc. However, LBNL medical records were not being received 

prior to this time. At that time, NIOSH began receiving the EE’s LBNL medical file in the DOL 

initial case file, which provided NIOSH with the X-ray information. Around 2011, NIOSH 

pursued re-requesting all pre-2010 claims for reviewing and re-sending of DOE records 

including the medical file, but given the workload by the LBNL site staff this was denied. 

NIOSH did not further pursue the LBNL record re-request, since the LBNL Site Profile would 

be revised for the LBNL DR Methodology, and a PER issued. A records re-request would be 

part of the PER process.

Recently, it was determined that the LBNL dosimetry records provided in the DOE response 

file may not have included all the bioassay records for an EE, based on a review of the

medical records in the DOL file. This is because a copy of the bioassay records are also 

saved in the EE’s LBNL medical file, according to bioassay laboratory record keeping 

procedures (LBL 1989). All LBNL claims received since 2010 have contained the bioassay 

records in the EE’s LBNL medical file located in the DOL initial case file. 

It should be noted that SC&A cited all but one claim that was received prior to this 2010 

timeframe that did not have the EE’s LBNL medical records in the DOL Initial case file. One 

claim SC&A cited was received after 2010, and contained the bioassay record in the medical 

file.

Therefore, in response to this observation and observation #3, NIOSH determined the 

current status of records receival from DOE, by reviewing all NOCTS claims post-2010 for 

discrepancies between the DOL initial case file and the DOE response file. Only 2 of the 105 

claims NIOSH reviewed had discrepancies, where the DOL initial case file had additional 

bioassay results that the DOE response file did not provide. 

For these two claims, NIOSH has re-requested the data review and response from DOE and 

pointed out the discrepancies. NIOSH will request that LBNL/DOE begin sending the entire 
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Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 16 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

medical file as part of their response, since the x-ray information and bioassay results are 

included in this file. As for pre-2010 claims, NIOSH has begun the process of requesting that 

DOE/LBNL re-review and re-send records for all non-compensatory, non-SEC claims, using 

the new process of sending the entire medical file.

With this records request process, including the entire LBNL medical file, in conjunction with 

the typical DR SRDB review, DOL initial case file review, and CATI review, NIOSH is confident 

in its ability to ascribe exposure potential for the LBNL employees given the LBNL policy of 

monitoring workers who worked with or in areas that contained unsealed radioactive 

sources. If from this review it is determined the worker has a potential for radiation 

exposure, then dose will be assigned according to the methodology in this white paper.

April 5, 2019 WG Meeting

At the 4/5/19 LBNL WG meeting, NIOSH provided the following update for Observation 2:

NIOSH made a mass re-request of data from LBNL for all claims that were submitted to 

NIOSH prior to 2010 and were not compensated under the SEC or through the dose 

reconstruction process (DR POC<50%). This equaled 166 claims. Of these 166 claims NIOSH 

has received responses with updated data files for 25 of them. An additional 52 of the 

claims didn't have a medical file and NOCTS was updated with this information. NIOSH is 

working with LBNL to determine the best way to transmit the data for the remaining 89.

With the current records request process, in conjunction with the typical DR SRDB review, 

DOL initial case file review, and CATI review, NIOSH is confident in its ability to ascribe 

exposure potential for the LBNL employees given the LBNL policy of monitoring workers 

who worked with or in areas that contained unsealed radioactive sources. If from this 

review it is determined the worker has a potential for radiation exposure, then dose will be 
Effective Date: 10/29/2019 (Final) Responses to SCA-TR-2018-SP003 Page 17 of 18

Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 17 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Item No. Issue Issue explanation Revised/updated NIOSH response

assigned according to the methodology in this white paper.

Per the transcript (attached, p. 86-87), SC&A suggested and the WG agreed with reviewing 

the data provided in the mass re-request to determine if this cleared up the issues of 

missing data that were previously found.

October 2019 Update

As discussed in previous matrix/BRS entries, on December 4, 2018, NIOSH made a mass rerequest of “the complete medical records file” for LBNL claims that had been received prior 

to 2010. By September 12, 2019, NIOSH received responses to all requests, had screened 

responses for new information, and reviewed the new information to determine priority for 

dose reconstruction revisions, as well as determined if the new information had been 

previously available via some other means. 

This LBNL mass supplemental request was made for 168 claims (updated number). Of these

168 claims, 53 claims had no record of a medical file and needed no further review. 

Additionally, there was 1 claim that had been submitted with a probability of causation 

(PoC) over 50%, which needed no further screening.

For the remaining 114 claims, 109 claims had no new bioassay information, 3 claims had 

new bioassay information compared to what LBNL had previously provided but this 

information was available to NIOSH from other documents (DOL files, data captures, etc.), 

and 2 claims had totally new bioassay information. Therefore, only 2 of the 168 (~1.2%)

claims had totally new information that was not previously available to NIOSH. The 5 claims 

that had new bioassay information received from LBNL were reviewed for impact. The PoC 

remained under 50% for these claims, when the new information was assessed.
Effective Date: 10/29/2019 (Final) Responses to SCA-TR-2018-SP003 Page 18 of 18

Responses: Lawrence Berkeley National Laboratory Dose Reconstruction Methodology 

Page 18 of 18

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

References:

American National Standard Institute/Health Physics Society Standard, 2012, Sampling and Monitoring Releases of Airborne Radioactivity in the Workplace; 

ANSI/HPS N13.56-2012.

Garden, 1960, Criteria in Glove Box Design, Function & Operation; N. B. Garden, March 1960. [SRDB Ref ID: 21603]

LBL (Lawrence Berkeley Laboratory), 1951, The UCRL Handbook of Health Chemistry Monitoring, University of California, Berkeley, California. [SRDB Ref 

ID: 21522] 

LBL (Lawrence Berkeley Laboratory), 1989, Lawrence Berkeley Laboratory Radiochemical Assay Chemical Procedures, University of California, Berkeley, 

California, May. [SRDB Ref ID: 72000]

LBNL (Lawrence Berkeley National Laboratory), 1981, The Environmental Health and Safety Department Operational Guide for the Health and Safety 

Representative, Lawrence Berkeley National Laboratory, University of California, Berkeley, CA. December 1981. [SRDB Ref. ID 21984]

LRL (Lawrence Radiation Laboratory), 1968, Safety Services Department, Services and Equipment, UCRL-17533, University of California, Berkeley, 

California, January 15. [SRDB Ref ID: 21520] 

Nuclear Regulatory Commission, 1992, Air Sampling in the Workplace, Revision 1, Regulatory Guide 8.25 [SRDB Ref ID: 20128].

Nuclear Regulatory Commission, 1993, Air Sampling in the Workplace, NUREG 1400 [SRDB Ref ID: 20129]. 

ORAUT (Oak Ridge Associated Universities Team), 2010, ORAUT-TKBS-0049, Site Profile for the Lawrence Berkeley National Laboratory, Rev 02, May 10, 2010. 

[SRDB Ref ID: 81254]